Although the FDA ruling purported to be a ‘risk assessment’, the document was nothing of the sort as it did not comply with the standards of practice endorsed and espoused by the professional risk assessment community.

The International Academy of Oral Medicine and Toxicology (IAOMT), a scientific organization made up ofdental, medical and research professionals submitted a petition for reconsideration to the FDA in September of 2009. This petition pointed out the inaccuracies, inconsistencies and flawed science the FDA relied upon, and urged them to reconsider their ruling. The FDA held a new dental products panel meeting in December 2010, specifically to further investigate and re-evaluate the issues brought up in the petition for reconsideration.